Privacy Policy

Effective Date: February 24, 2026

1. Introduction

This Privacy Policy applies to the platform TopSend, which operates as a sub-brand of Maknak L.L.C-FZ, a company registered in Meydan Free Zone, Dubai, United Arab Emirates.

Maknak L.L.C-FZ acts as the legal entity responsible for processing user data in accordance with this Privacy Policy.

By using our services, you agree to the terms outlined in this policy.

2. Information We Collect

2.1 Personal Information

  • Full name
  • Email address
  • Phone number
  • Account information

2.2 Order Information

  • Recipient phone number for top-ups
  • Game ID or account identifier
  • Transaction details

2.3 Payment Information

Payments are processed securely through authorized third-party payment providers, including Stripe.

We do not store full credit card details on our servers. Payment data is handled directly by the payment processor.

2.4 Technical Information

  • IP address
  • Device type
  • Browser type
  • Operating system
  • Usage and interaction data

Contacts Information (Optional)

With your explicit permission, TopSend may access your device contacts (including names and phone numbers) to help you identify recipients for sending services such as mobile top-ups.

If you grant access, your contacts may be securely uploaded to our servers for the sole purpose of identifying which of your contacts can receive services through our platform.

We do not access, upload, or process your contacts without your prior consent.

3. Purpose of Data Collection

We process user data for the following purposes:

  • Processing and delivering digital services
  • Fraud prevention and risk monitoring
  • Compliance with Anti-Money Laundering (AML) laws
  • Compliance with international sanctions regulations
  • Customer support
  • Service improvement and security enhancement
  • Identifying which of your contacts can receive services through our platform (only if you grant permission)

We do not sell personal data to third parties.

4. Sharing of Information

Information may be shared with:

  • Payment processors
  • Telecommunications operators
  • Gaming credit providers
  • Legal or regulatory authorities when required by law

Data sharing is limited to what is necessary to provide services or comply with legal obligations.

We do not sell, rent, or share your contacts with third parties for marketing purposes.

Contacts data is used strictly for internal matching purposes and service functionality.

5. International Data Transfers

Due to the international nature of our services, data may be processed in:

  • United Arab Emirates
  • European Union
  • Other jurisdictions where our service providers operate

We implement appropriate safeguards for international data transfers.

6. Data Retention

Transaction and account data may be retained for up to five (5) years to comply with financial regulations, tax requirements, AML obligations, and dispute resolution needs.

After the retention period, data will be securely deleted or anonymized.

7. Data Security

We implement appropriate technical and organizational measures, including:

  • SSL encryption
  • Secure servers
  • Restricted internal access
  • Fraud monitoring systems

However, no online system can guarantee absolute security.

8. User Rights

Subject to applicable laws, users may request:

  • Access to personal data
  • Correction of inaccurate information
  • Deletion of personal data (where not restricted by financial or AML regulations)

Requests can be submitted through the contact details below.

9. AML & Sanctions Compliance

TopSend and Maknak L.L.C-FZ comply with international sanctions regulations and Anti-Money Laundering (AML) requirements.

We reserve the right to conduct identity verification (KYC) and to refuse, suspend, or cancel transactions that violate applicable regulations.

10. Cookies

Our website may use cookies to improve functionality, analyze usage, and enhance user experience.

Users may manage cookie preferences through their browser settings.

11. Changes to This Policy

We reserve the right to update this Privacy Policy at any time. Continued use of our services constitutes acceptance of the updated version.

12. Legal Information & Contact Details

  • Legal Entity: Maknak L.L.C-FZ
  • Trade License Number: 2534073.01
  • Issuing Authority: Meydan Free Zone – Dubai, United Arab Emirates
  • Contacts Data Usage and Consent

    TopSend respects your privacy and only accesses your contacts with your explicit consent.

    Before accessing your contacts, we clearly inform you within the app about:

    • Why we need access
    • How your contacts will be used
    • Whether your data will be uploaded to our servers

    If you agree, your contacts may be securely transmitted to our servers to identify which of your contacts are eligible to receive services through TopSend.

    You can:

    • Deny access at any time
    • Revoke permission from your device settings

    We do not use your contacts for any purpose other than providing the intended service.